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WOODWORTH v. COMMISSIONER OF INTERNAL REVENUE

No. 12158.

218 F.2d 719 (1955)

Anna I. WOODWORTH et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

January 27, 1955.

Attorney(s) appearing for the Case

L. F. Loux, Cleveland, Ohio (Orgill, Klein, Loux & Wickham, Cleveland, Ohio, on the brief), for petitioners.

S. Dee Hanson, Washington, D. C. (H. Brian Holland, Ellis N. Slack, Lee A. Jackson and L. W. Post, Washington, D. C., on the brief), for respondent.

Before SIMONS, Chief Judge, and MARTIN and STEWART, Circuit Judges.

STEWART, Circuit Judge.

The question here is whether the petitioners realized the equivalent of a taxable dividend in 1945 upon cancellation by a corporation of shares of stock standing in their names coincident with cancellation of their notes payable to the corporation. The Commissioner determined that the surrounding circumstances brought the transaction within the reach of § 115(g) of the Internal Revenue Code then in effect,1

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